On 8/25/23, the IRS announced that Interest rates increase for the fourth quarter 2023 would increase to 8% per year for the calendar quarter beginning 10/1/23 for taxes owed but not fully paid by individual taxpayers...more
Accuracy-related penalties under section 6662 are among the most common penalties in the Tax Code. As a result, they are often at issue in tax litigation against the IRS. That raises the question: What are the burdens of...more
It is tax season once again. While the Internal Revenue Service (IRS) has extended this year’s filing deadline to May 17, 2021 for individuals, businesses must still file by April 15, and all U.S. taxpayers must ensure that...more
Recent Announcements - The Oregon Department of Revenue (the “Department”) has made several recent announcements regarding Oregon’s new Commercial Activity Tax (the “CAT”). In an email dated December 4, 2019, the...more
We are taking a break from our multi-post coverage of Opportunity Zones to address a recent, significant piece of Oregon tax legislation. On May 16, 2019, Governor Kate Brown signed into law legislation imposing a new...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 25 – March 1, 2019. February 25, 2019: The IRS issued Revenue Ruling 2019-05,...more
The IRS Automated Underreporter Matching Process matches Tax Returns against Information Returns. IRS states that there were approximately 150 million individual tax returns filed in 2017 and about 25 million of them (17%)...more
According to the IRS, accuracy related penalties remain the number one most litigated tax issue. The Internal Revenue Code authorizes the IRS to impose penalties if a Taxpayer is negligent or disregards tax rules and...more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more
Certain important changes took effect on January 1, 2018 regarding underpayment of taxes by partnerships as well as the handling of tax inquiries including audits. The biggest change is that the IRS can now come to collect...more
Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more